Rodriguez v. United States

PETITIONER: Dennys Rodriguez
RESPONDENT: United States
LOCATION: Highway 275, Meigs Street Intersection

DOCKET NO.: 13-9972
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 575 US (2015)
GRANTED: Dec 02, 2014
ARGUED: Jan 21, 2015
DECIDED: Apr 21, 2015

ADVOCATES:
Ginger D. Anders - for the respondent
Shannon P. O'Connor - for the petitioner

Facts of the case

On March 27, 2012, a Nebraska K-9 police officer pulled over a vehicle driven by Dennys Rodriguez after his vehicle veered onto the shoulder of the highway. The officer issued a written warning and then asked if he could walk the K-9 dog around Rodriguez's vehicle. Rodriguez refused, but the officer instructed him to exit the vehicle and then walked the dog around the vehicle. The dog alerted to the presence of drugs, and a large bag of methamphetamine was found.

Rodriguez moved to suppress the evidence found in the search, claiming the dog search violated his Fourth Amendment right to be free from unreasonable seizures. The district court denied the motion. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed, holding the search was constitutional because the brief delay before employing the dog did not unreasonably prolong the otherwise lawful stop.

Question

Is the use of a K-9 unit, after the conclusion of a traffic stop and without reasonable suspicion of criminal activity, a violation of the Fourth Amendment prohibition on unreasonable search and seizures?

Media for Rodriguez v. United States

Audio Transcription for Oral Argument - January 21, 2015 in Rodriguez v. United States

Audio Transcription for Opinion Announcement - April 21, 2015 in Rodriguez v. United States

John G. Roberts, Jr.:

Justice Ginsburg has our opinion in Case 13-9972, Rodriguez v. United States.

Ruth Bader Ginsburg:

Does the Fourth Amendment, which shields people from unreasonable searches and seizures by law enforcement personnel, permit police on stopping a vehicle for a traffic offense to detain the car and driver to seek evidence of crimes unrelated to the traffic offense?

Our answer, police may not prolong detention of car and driver beyond the time reasonably required to address the traffic violation.

We so stated 10 years ago in Illinois v. Caballes and today adhere to the line drawn in Caballes.

The episode in controversy, Officer Struble, a K-9 officer policing Nebraska roads, pulled Rodriguez over for driving on a highway shoulder in violation of Nebraska's traffic code.

After attending to everything related to the traffic stop, Struble handled Rodriguez a written warning.

He then asked Rodriguez for permission to walk his dog around the vehicle.

When Rodriguez refused consent, Struble detained him, pending the arrival of a second officer.

After that officer arrived Struble retrieved his dog, who alerted to the presence of drugs in Rodriguez's car.

Seven or eight minutes elapsed from issuance of the warning until the dog alerted.

Indicted on federal drug charges Rodriguez moved to suppress the evidence seized from the car.

The magistrate judge, an intern of the District Court, found that the traffic stop had been prolonged without reasonable suspicion in order to conduct the dog sniff.

But they ruled under controlling Eight Circuit precedent, extending the stop by seven or eight minutes ranked as a de minimis intrusion and was therefore permissible.

Agreeing that the evidence detected by the dog was admissible, the Court of Appeals affirmed Rodriguez's drug conviction.

We vacate the Court of Appeals judgment.

The Court held in Illinois v. Caballes that a dog sniff conducted during a lawful traffic stop is compatible with the Fourth Amendment if the sniff does not lengthen the roadside detention.

The tolerable duration of a traffic stop is determined by its mission, which is to address the traffic violation that warranted the stop and attend to related safety concerns.

As we cautioned in Caballes, a traffic stop does not license police to pursue unrelated investigations that prolong attention of car and driver beyond the time it takes to complete the stop's traffic centered mission. That mission typically includes checking the driver's license, determining whether there are outstanding warrants against the driver, and inspecting the automobile's registration and proof of insurance.

These checks serve the same objective as enforcement of the traffic code.

They are viewed to ensuring that vehicles on the road are operated safely and responsibly.

A dog sniff, unlike those stock inquiries, lacks the same tie to roadway safety.

For its de minimis rule the Eighth Circuit relied on this Court's decision in Pennsylvania v. Mimms.

There we held that as a safety precaution an officer may order a driver to exit a lawfully stopped vehicle.

The officer's safety interest in Mimms however stemmed from the danger of the stop itself.

The dog sniffing contrast aims to detect unrelated crimes and thus detours from the officer's traffic control mission.

The government asks us to uphold the Eighth Circuit's judgment by focusing on whether the total duration of the stop was reasonable in comparison to other traffic stops involving similar circumstances.

In effect, the government argues that by completing all traffic related tasks quickly, an officer can earn bonus time to pursue an unrelated criminal inquiry.

We look instead to the officer's actual conduct, did he, as Officer Struble testified, get all the business of the stop out of the way before tacking on a dog sniff?

As we indicated in Caballes and hold today, a traffic stop becomes unlawful if prolonged beyond the time in fact needed to complete all traffic based inquires.

Although we vacate the Eighth Circuit's judgment, we remand the case for consideration of a question not reached by the Court of Appeals, did the police have a reasonable basis independent of the traffic offense to suspect that Rodriguez was engaged in drug dealing?

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